Registrar and Share Transfer Agent

Code of conduct

CODE OF CONDUCT FOR BOARD MEMBERS AND SENIOR MANAGEMENT PERSONNEL OF OCEANAA BIOTEK INDUSTRIES LIMITED

The members of the Board of Directors of Oceanaa Biotek Industries Limited acknowledge and accept the scope and extent of their duties as Directors. They have a responsibility to carry out their duties in an honest and businesslike manner and within the scope of their authority, as set forth in the laws of India as well as in the Memorandum and Articles of Association of the Company. They are entrusted with and are responsible for the oversight of the assets and business affairs of the Company in an honest, fair, diligent and ethical manner. As Directors, they must act within the bounds of the authority conferred upon them and with the duty to make and enact informed decisions and policies in the best interests of the Company.

The Board of Directors has adopted the above Code of Conduct and the Directors and Senior Managers are expected to adhere to the standards of care, loyalty, good faith and the avoidance of conflicts of interest.

A Director or Senior Manager who has concerns regarding compliance with this Code should raise those concerns with the Chairman of the Board and the Chairman of the Audit Committee, who will determine what action shall be taken to deal with the concern. In the extremely unlikely event that a waiver of this Code for a Director would be in the best interest of the Company, it must be approved by the Audit Committee and the Board of Directors.

For this purpose "Senior Management" shall mean members of Management one level below the executive directors and shall include all functional heads.